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RFE phraseThe standard of review

Treasure Craft: assertions without documents: what it means in an RFE or denial

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Going on record without supporting documentary evidence is not sufficient for purposes of meeting the burden of proof in these proceedings.
USCIS Policy Manual, Vol. 1, Part E, Ch. 4 (burden and standards of proof)

What it means

Kazarian

Kazarian is the court precedent that established the two-step EB-1A review: first a formal count of the criteria (at least 3 of 10 required), then final merits - a holistic assessment of whether the evidence really shows extraordinary ability. USCIS applies this approach to every EB-1A case.

The practical consequence: 'ticking three criteria' off a checklist is not enough. The same evidence is weighed on the merits at step two, so a strong petition builds a coherent story of recognition in the field out of it.

How officers apply the two-step analysis is visible in the published AAO decisions in the database on this site.

The glossary entry

From the knowledge base: Glossary of Terms for U.S. Talent Visas O-1, EB-1, EB-2

This is the layer of terminology that separates people who just read instructions from those who understand the reasoning behind denials. All these terms appear in AAO decisions and in RFE texts, and without knowing them, it is impossible to understand why some cases are denied despite meeting all criteria.

Read the full article

The precedent behind the sentence

Treasure Craft · Matter of Treasure Craft of California, 14 I&N Dec. 190 (BIA 1972)

An assertion with no document behind it is not evidence.

  • The line that gets quoted: going on record without supporting documentary evidence does not meet the burden of proof. Matter of Soffici (1998) usually appears alongside it - the same point, and the two have been cited as a pair ever since.
  • In practice: a letter saying "the beneficiary is widely recognised" proves only that its author thinks so. The evidence is what the letter points AT - the invitation, the contract, the publication, the minutes.
  • Which is why a stack of similar recommendation letters with no exhibits behind them draws this citation almost every time.

Seen in 9 of 150 parsed notices, across 7 desks.

The precedent page

Matter of Soffici · Matter of Soffici, 22 I&N Dec. 158 (Comm. 1998)

The same point as Treasure Craft: without supporting documents an assertion does not carry.

  • The 1998 decision restates the Treasure Craft line, and since then the two are cited together almost every time. No separate page: two appearances in this corpus, both alongside Treasure Craft.

Seen in 2 of 150 parsed notices, across 2 desks.

Questions and answers on the site

Distilled from the public community chats, anonymised; corpus as of June 2026. These are participants' observations, not legal advice and not USCIS statistics.

Related

All RFE phrasesRFE by criterionPrecedents officers citeAfter a denial← "The petitioner has not established"Matter of Ho: inconsistencies in the record →

Frequently asked questions

What does "Treasure Craft: assertions without documents" mean?
Kazarian is the court precedent that established the two-step EB-1A review: first a formal count of the criteria (at least 3 of 10 required), then final merits - a holistic assessment of whether the evidence really shows extraordinary ability. USCIS applies this approach to every EB-1A case.
Where is this stated officially?
USCIS Policy Manual, Vol. 1, Part E, Ch. 4 (burden and standards of proof): https://www.uscis.gov/policy-manual/volume-1-part-e-chapter-4
Which precedent is behind it?
Treasure Craft - An assertion with no document behind it is not evidence.

The sentence is quoted from its official source (link under the quote); the explanation is assembled from the site glossary, the precedent notes, the knowledge base and distilled community observations. Not legal advice; the site is not affiliated with USCIS.